In the United States v. Sanges case of 1891, the Supreme Court ruled on a matter concerning copyright law and its application to circus performances. The plaintiff, Imre Kiralfy, held copyrights for two ballets which he alleged were being infringed upon by defendant Antonio Sanges in his circus shows. The court had to determine whether these performances constituted "dramatic compositions" under copyright law. Ultimately, it was decided that they did not; while certain elements such as costumes and scenery might be protected under copyright if separately registered, the overall performance could not be copyrighted as a dramatic composition because it lacked dialogue or narrative structure - key components of what is considered 'drama'. Therefore, no infringement took place according to this interpretation of U.S Copyright Law at that time.

In the dissenting opinion for United States v. Sanges, Justice Lamar disagreed with the majority's interpretation of jurisdictional boundaries between federal and state courts. He argued that the case should not have been tried in a federal court because it involved an issue of state law - specifically, whether or not a certain act constituted manslaughter under Louisiana law. According to Justice Lamar, this was clearly within the purview of Louisiana's courts rather than those of the U.S. government. Furthermore, he contended that allowing such cases to be heard by federal judges would undermine states' rights and upset the balance between national and local authority established by America's founders.